Ethics and Human Rights

Code of Ethics

Orano's Code of Ethics was updated in 2016, superseding the Values Charter in force since 2003. Available on the Orano website (www.orano.group) and issued to all of our employees and industrial partners (subcontractors, suppliers, business partners, customers), the Orano Code of Ethics sets out the Orano's ethical commitments to its stakeholders, as well as what it expects from its employees and its suppliers or subcontractors and business partners; it specifies the rules of conduct which everyone must follow at all times.

It is complemented by a Compliance Policy which specifies how the Code is to be implemented at all levels, across all activities and in all countries; this policy also explains how compliance is organized within the group. In order to pursue compliance with the anti-corruption requirements of the Sapin II Act of December 9, 2016, and in accordance with the recommendations issued at the end of 2017 by the French anti-corruption agency AFA (Agence Française Anticorruption), a number of complementary processes have been launched and will continue in 2018, such as the updating of the anti-corruption code of conduct and its incorporation into the internal regulations of Orano Mining and all its subsidiaries, the design of an e-learning course specifically developed on the basis of the Orano Code of Ethics, and its deployment to all employees, the systematization of the partner compliance verification process according to level of risk, and the reinforcement of the formalization of certain controls, especially regarding accounting transactions.

According to the Code of Ethics, it is a reflex and a duty for each and every one of us to immediately raise the alert if any blatant incident or breach of a statutory or regulatory obligation or violation of this code of ethics or compliance policies and procedures is observed. There are no hierarchical barriers to the internal circulation of information required to ensure the smooth running of Orano, nor any requisite rank for anyone alerting their superiors or a compliance manager forthwith. This applies with the full force of legal protection provide for under the Sapin II Act concerning whistleblowers acting in good faith.

The rules of conduct of the Code of Ethics deal with the action we take in terms of the following:

compliance with international treaties (international mechanisms in force with regard to non-proliferation);

conflicts of interest;

insider trading;

corruption, gifts and unfair advantage, andinfluence peddling;

payments and relations with third parties;

relations with commercial intermediaries;

advocacy and lobbying and political funding;

philanthropy, sponsoring, donations, humanitarian work;

competition;

protection of people and assets;

ethics alert and the primacy of the Orano Code of Ethics.

At group level, the Orano Board of Directors has set up four specialized committees including the Audit and Ethics Committee. Its mission includes overseeing group compliance with the best international ethical practices, reviewing the Code of Ethics and its updates and where appropriate making recommendations to the Board of Directors. The role of Compliance Officer within the Mining Business Unit is held by the General Counsel for our activities, in contact with the Senior Vice President for Compliance of the Orano Group on the Group Audit and Ethics Committee.

Ethical reporting

Orano Mining, like all the group's business entities, conducts an internal ethical reporting process on the proper application of the Code of Ethics, any infringements observed, and action plans put in place to remedy such breaches.

Each campaign opens with a letter from the Senior Executive Vice President of Orano Mining, in application of the letter of instruction from the Orano group CEO. This process involves all our directors and their managerial staff in all the countries where we are present (Orano Mining and its sites in France and abroad, as well as its subsidiaries).

This reporting is underpinned by the principle that our employees can report an infringement they have found without repercussion to themselves if the facts are proven (whether the issue is within our own operations or related to the practices of our subcontractors). In the same way, if anyone is given an order that clearly goes against the Orano Code of Ethics, they are entitled not to comply and must report the matter to group management immediately.

The nature of corrective actions proposed varies depending on the severity of the failure to comply with the Code. These actions may range, for example, from training to dismissal of the personnel concerned. This exercise also enables our teams on all our sites to have a better qualitative understanding of the situations that bear risks with regard to the rules of conduct and the Code's values: corruption, conflict of interest, forced or child labor, etc.

All members of the Orano Mining Management Committee have followed or will follow training in ethics and human rights. Similarly, all of our subcontractors and suppliers, in subscribing to our General Purchasing Conditions, make a contractual undertaking to uphold the Code of Ethics.

Since 2016, monitoring of ethical incidents has been conducted within the Orano Mining Management Committee at least twice yearly.

Indigenous peoples' rights

The right of indigenous peoples to decide on the basis of prior and informed free consent is one of the undertakings necessary for the acceptability of our activities and for building a constructive dialogue over the long term.

More specifically, in Mongolia and in Canada, we seek to establish respect for these fundamentals at the earliest possible stage in the life cycle of mining activities.

The way in which we approach and deal with the questions surrounding this complex issue in concrete terms is currently being examined by our different functions. As part of this process we are involved in an ICMM working group and we situate this important initiative as one of our continuous improvement priorities.

System for alerting and issuing complaints in case of discrimination

Discrimination is unequal treatment based on grounds prohibited by law. French law recognizes twenty grounds or criteria of discrimination: age, gender, origin, family status, sexual orientation, gender identity, customs, genetic features, belonging or not to an ethnic group, nation, race, or given religion, physical appearance, disability, health status, pregnancy, family name, political opinions, trade union activities, place of residence (twentieth criterion, in the Law of February 21, 2014 on Planning for Cities and Urban Cohesion).

It is different from a discriminatory behavior or act, which is a discriminatory gesture or action of one employee towards another, based on one of the twenty grounds of discrimination.

Find out more

A system for alerting and issuing complaints in case of discrimination has been in place since February 2013.

Our employees can use this system or else raise any issue with the human resources teams, their managers, their staff representative, or the network of compliance officers.

In 2017, the system was used five times within the scope of mining activities. All these cases were substantiated and in each case an internal investigation was conducted. In two cases, a reminder of the procedures was issued, in one case discussions are in progress with those involved, one case led to a resignation, and in the last case the person responsible could not be identified but employees potentially involved have been made aware of the issue.